> CA operators MUST apply to Mozilla for inclusion of their next generation 
> root certificate at least 2 years before the distrust date of the CA 
> certificate they wish to replace.

Hi Ben.  I would interpret that sentence to mean that if a CA operator misses 
the "at least 2 years" deadline then they are forever forbidden from submitting 
a next generation root certificate for inclusion in Mozilla's root store.  Is 
that the intent?

I think CAs should certainly be encouraged to submit next gen roots in a timely 
fashion, and I think Mozilla shouldn't feel obliged to grant extensions on 
to-be-replaced root removals in order to support CAs that fail to do this "at 
least 2 years" in advance.  However, I think "forever forbidden" is 
unnecessarily harsh!

So I suggest changing "MUST" to "SHOULD".

________________________________
From: [email protected] <[email protected]> on 
behalf of Ben Wilson <[email protected]>
Sent: 26 July 2023 16:42
To: [email protected] <[email protected]>
Subject: MRSP 2.9: Issue#232: Root CA Lifecycles


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All,

We previously announced this change in policy over a year ago, and will be 
finalizing it in Version 2.9 of the Mozilla Root Store Policy (MRSP).
Please review this addition, and let us know if you have any final comments.

----- Begin MRSP Revision -----

7.4 Root CA Lifecycles
For a root CA certificate trusted for server authentication, Mozilla will 
remove the websites trust bit when the CA key material is more than 15 years 
old. For a root CA certificate trusted for secure email, Mozilla will set the 
"Distrust for S/MIME After Date" for the CA certificate to 18 years from the CA 
key material generation date. The CA key material generation date SHALL be 
determined by reference to the auditor-witnessed key generation ceremony 
report. If the CA operator cannot provide the key generation ceremony report 
for a root CA certificate created before July 1, 2012, then Mozilla will use 
the “Valid From” date in the root CA certificate to establish the key material 
generation date. For transition purposes, root CA certificates in the Mozilla 
root store will be distrusted according to the schedule located at 
https://wiki.mozilla.org/CA/Root_CA_Lifecycles, which is subject to change if 
underlying algorithms become more susceptible to cryptanalytic attack or if 
other circumstances arise that make this schedule obsolete.
CA operators MUST apply to Mozilla for inclusion of their next generation root 
certificate at least 2 years before the distrust date of the CA certificate 
they wish to replace.

----- End MRSP Revision -----

Thanks,

Ben

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